ACRP SYNTHESIS 17. Approaches to Integrating Airport Development and Federal Environmental Review Processes. A Synthesis of Airport Practice

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Approaches to Integrating

Airport Development and

Federal Environmental

Review Processes

COOPERATIVE

RESEARCH

PROGRAM

ACRP

SYNTHESIS 17

the Federal

Aviation Administration

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VICE CHAIR JEFF HAMIEL Minneapolis–St. Paul

Metropolitan Airports Commission

MEMBERS JAMES CRITES

Dallas–Ft. Worth International Airport RICHARD DE NEUFVILLE Massachusetts Institute of Technology KEVIN C. DOLLIOLE

Unison Consulting JOHN K. DUVAL Beverly Municipal Airport KITTY FREIDHEIM Freidheim Consulting STEVE GROSSMAN Oakland International Airport TOM JENSEN

National Safe Skies Alliance CATHERINE M. LANG Federal Aviation Administration GINA MARIE LINDSEY Los Angeles World Airports CAROLYN MOTZ Hagerstown Regional Airport RICHARD TUCKER Huntsville International Airport

EX OFFICIO MEMBERS SABRINA JOHNSON

U.S. Environmental Protection Agency RICHARD MARCHI

Airports Council International— North America

LAURA McKEE

Air Transport Association of America HENRY OGRODZINSKI

National Association of State Aviation Officials

MELISSA SABATINE American Association of Airport

Executives

ROBERT E. SKINNER, JR. Transportation Research Board

SECRETARY

CHRISTOPHER W. JENKS Transportation Research Board

*Membership as of June 2009. *Membership as of June 2009.

Governments, Arlington

Executive Director:Robert E. Skinner, Jr., Transportation Research Board

MEMBERS

J. BARRY BARKER, Executive Director, Transit Authority of River City, Louisville, KY ALLEN D. BIEHLER, Secretary, Pennsylvania DOT, Harrisburg

LARRY L. BROWN, SR.,Executive Director, Mississippi DOT, Jackson

DEBORAH H. BUTLER,Executive Vice President, Planning, and CIO, Norfolk Southern Corporation, Norfolk, VA

WILLIAM A.V. CLARK,Professor, Department of Geography, University of California, Los Angeles

DAVID S. EKERN, Commissioner, Virginia DOT, Richmond

NICHOLAS J. GARBER, Henry L. Kinnier Professor, Department of Civil Engineering, University of Virginia, Charlottesville

JEFFREY W. HAMIEL,Executive Director, Metropolitan Airports Commission, Minneapolis, MN EDWARD A. (NED) HELME, President, Center for Clean Air Policy, Washington, DC

WILL KEMPTON, Director, California DOT, Sacramento SUSAN MARTINOVICH, Director, Nevada DOT, Carson City DEBRA L. MILLER, Secretary, Kansas DOT, Topeka

NEIL J. PEDERSEN, Administrator, Maryland State Highway Administration, Baltimore PETE K. RAHN, Director, Missouri DOT, Jefferson City

SANDRA ROSENBLOOM, Professor of Planning, University of Arizona, Tucson TRACY L. ROSSER,Vice President, Regional General Manager, Wal-Mart Stores, Inc.,

Mandeville, LA

ROSA CLAUSELL ROUNTREE,CEO–General Manager, Transroute International Canada Services, Inc., Pitt Meadows, BC

STEVEN T. SCALZO, Chief Operating Officer, Marine Resources Group, Seattle, WA HENRY G. (GERRY) SCHWARTZ, JR., Chairman (retired), Jacobs/Sverdrup Civil, Inc.,

St. Louis, MO

C. MICHAEL WALTON,Ernest H. Cockrell Centennial Chair in Engineering, University of Texas, Austin

LINDA S. WATSON,CEO, LYNX–Central Florida Regional Transportation Authority, Orlando STEVE WILLIAMS, Chairman and CEO, Maverick Transportation, Inc., Little Rock, AR

EX OFFICIO MEMBERS

THAD ALLEN (Adm., U.S. Coast Guard),Commandant, U.S. Coast Guard, Washington, DC PETER H. APPEL,Administrator, Research and Innovative Technology Administration, U.S.DOT J. RANDOLPH BABBITT, Administrator, Federal Aviation Administration, U.S.DOT

REBECCA M. BREWSTER, President and COO, American Transportation Research Institute, Smyrna, GA

GEORGE BUGLIARELLO, President Emeritus and University Professor, Polytechnic Institute of New York University, Brooklyn; Foreign Secretary, National Academy of Engineering, Washington, DC

JAMES E. CAPONITI, Acting Deputy Administrator, Maritime Administration, U.S.DOT CYNTHIA DOUGLASS, Acting Deputy Administrator, Pipeline and Hazardous Materials Safety

Administration, U.S.DOT

LEROY GISHI, Chief, Division of Transportation, Bureau of Indian Affairs, U.S. Department of the Interior, Washington, DC

EDWARD R. HAMBERGER, President and CEO, Association of American Railroads, Washington, DC JOHN C. HORSLEY, Executive Director, American Association of State Highway and

Transportation Officials, Washington, DC

ROSE A. MCMURRY, Acting Deputy Administrator, Federal Motor Carrier Safety Administration, U.S.DOT

RONALD MEDFORD, Acting Deputy Administrator, National Highway Traffic Safety Administration, U.S.DOT

WILLIAM W. MILLAR, President, American Public Transportation Association, Washington, DC JEFFREY F. PANIATI, Acting Deputy Administrator and Executive Director, Federal Highway

Administration, U.S.DOT

PETER ROGOFF,Administrator, Federal Transit Administration, U.S.DOT JOSEPH C. SZABO, Administrator, Federal Railroad Administration, U.S.DOT

ROBERT L. VAN ANTWERP (Lt. Gen., U.S. Army), Chief of Engineers and Commanding General, U.S. Army Corps of Engineers, Washington, DC

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TRANSPORTATION RESEARCH BOARD

WASHINGTON, D.C. 2009 www.TRB.org

ACRP

SYNTHESIS 17

Research Sponsored by the Federal Aviation Administration

SUBJECTAREAS

Aviation

Approaches to Integrating

Airport Development and

Federal Environmental

Review Processes

A Synthesis of Airport Practice

CONSULTANTS

DONALD G. ANDREWS Reynolds Smith and Hills, Inc.

Houston, Texas DAVID J. FULL Reynolds Smith and Hills, Inc.

San Francisco, California and

MARY L. VIGILANTE Synergy Consultants, Inc.

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tem connects with other modes of transportation and where federal responsibility for managing and regulating air traffic operations intersects with the role of state and local governments that own and operate most airports. Research is necessary to solve common oper-ating problems, to adapt appropriate new technologies from other industries, and to introduce innovations into the airport industry. The Airport Cooperative Research Program (ACRP) serves as one of the principal means by which the airport industry can develop innovative near-term solutions to meet demands placed on it.

The need for ACRP was identiﬁed in TRB Special Report 272: Airport Research Needs: Cooperative Solutionsin 2003, based on a study sponsored by the Federal Aviation Administration (FAA). The ACRP carries out applied research on problems that are shared by airport operating agencies and are not being adequately addressed by existing federal research programs. It is modeled after the successful National Cooperative Highway Research Program and Transit Cooperative Research Program. The ACRP undertakes research and other technical activities in a variety of airport subject areas, including design, construction, maintenance, operations, safety, security, policy, planning, human resources, and adminis-tration. The ACRP provides a forum where airport operators can cooperatively address common operational problems.

The ACRP was authorized in December 2003 as part of the Vision 100-Century of Aviation Reauthorization Act. The primary participants in the ACRP are (1) an independent governing board, the ACRP Oversight Committee (AOC), appointed by the Secretary of the U.S. Department of Transportation with representation from airport operating agencies, other stakeholders, and relevant indus-try organizations such as the Airports Council International-North America (ACI-NA), the American Association of Airport Execu-tives (AAAE), the National Association of State Aviation Officials (NASAO), and the Air Transport Association (ATA) as vital links to the airport community; (2) the TRB as program manager and sec-retariat for the governing board; and (3) the FAA as program spon-sor. In October 2005, the FAA executed a contract with the National Academies formally initiating the program.

The ACRP beneﬁts from the cooperation and participation of air-port professionals, air carriers, shippers, state and local government officials, equipment and service suppliers, other airport users, and research organizations. Each of these participants has different interests and responsibilities, and each is an integral part of this cooperative research effort.

Research problem statements for the ACRP are solicited period-ically but may be submitted to the TRB by anyone at any time. It is the responsibility of the AOC to formulate the research program by identifying the highest priority projects and deﬁning funding levels and expected products.

Once selected, each ACRP project is assigned to an expert panel, appointed by the TRB. Panels include experienced practitioners and research specialists; heavy emphasis is placed on including airport professionals, the intended users of the research products. The panels prepare project statements (requests for proposals), select contractors, and provide technical guidance and counsel throughout the life of the project. The process for developing research problem statements and selecting research agencies has been used by TRB in managing coop-erative research programs since 1962. As in other TRB activities, ACRP project panels serve voluntarily without compensation.

Primary emphasis is placed on disseminating ACRP results to the intended end-users of the research: airport operating agencies, service providers, and suppliers. The ACRP produces a series of research reports for use by airport operators, local agencies, the FAA, and other interested parties, and industry associations may arrange for work-shops, training aids, ﬁeld visits, and other activities to ensure that results are implemented by airport-industry practitioners.

COPYRIGHT PERMISSION

Authors herein are responsible for the authenticity of their materials and for obtaining written permissions from publishers or persons who own the copyright to any previously published or copyrighted material used herein. Cooperative Research Programs (CRP) grants permission to reproduce material in this publication for classroom and not-for-profit purposes. Permission is given with the understanding that none of the material will be used to imply TRB or FAA endorsement of a particular product, method, or practice. It is expected that those reproducing the material in this document for educational and not-for-profit uses will give appropriate acknowledgment of the source of any reprinted or reproduced material. For other uses of the material, request permission from CRP.

NOTICE

The project that is the subject of this report was a part of the Airport Cooperative Research Program conducted by the Transportation Research Board with the approval of the Governing Board of the National Research Council. Such approval reﬂects the Governing Board’s judgment that the project concerned is appropriate with respect to both the purposes and resources of the National Research Council.

The members of the technical advisory panel selected to monitor this project and to review this report were chosen for recognized scholarly competence and with due consideration for the balance of disciplines appropriate to the project. The opinions and conclusions expressed or implied are those of the research agency that performed the research, and while they have been accepted as appropriate by the technical panel, they are not necessarily those of the Transportation Research Board, the National Research Council, or the Federal Aviation Administration of the U.S. Department of Transportation.

Each report is reviewed and accepted for publication by the technical panel according to procedures established and monitored by the Transportation Research Board Executive Committee and the Governing Board of the National Research Council.

The Transportation Research Board of the National Academies, the National Research Council, and the Federal Aviation Administration (sponsor of the Airport Cooperative Research Program) do not endorse products or manufacturers. Trade or manufacturers’ names appear herein solely because they are considered essential to the clarity and completeness of the project reporting.

Published reports of the

AIRPORT COOPERATIVE RESEARCH PROGRAM

are available from: Transportation Research Board Business Office

500 Fifth Street, NW Washington, DC 20001

and can be ordered through the Internet at http://www.national-academies.org/trb/bookstore

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ars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. On the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and techni-cal matters. Dr. Ralph J. Cicerone is president of the National Academy of Sciences.

The National Academy of Engineering was established in 1964, under the charter of the National Acad-emy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achieve-ments of engineers. Dr. Charles M. Vest is president of the National Academy of Engineering.

The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, on its own initiative, to identify issues of medical care, research, and education. Dr. Harvey V. Fineberg is president of the Institute of Medicine.

The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Acad-emy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scien-tific and engineering communities. The Council is administered jointly by both the Academies and the Insti-tute of Medicine. Dr. Ralph J. Cicerone and Dr. Charles M. Vest are chair and vice chair, respectively, of the National Research Council.

The Transportation Research Board is one of six major divisions of the National Research Council. The mission of the Transportation Research Board is to provide leadership in transportation innovation and progress through research and information exchange, conducted within a setting that is objective, interdisci-plinary, and multimodal. The Board’s varied activities annually engage about 7,000 engineers, scientists, and other transportation researchers and practitioners from the public and private sectors and academia, all of whom contribute their expertise in the public interest. The program is supported by state transportation depart-ments, federal agencies including the component administrations of the U.S. Department of Transportation, and other organizations and individuals interested in the development of transportation. www.TRB.org

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MEMBERS GARY C. CATHEY

California Department of Transportation KEVIN C. DOLLIOLE

Unison Consulting, Inc. JULIE KENFIELD Jacobs

CAROLYN MOTZ

Hagerstown Regional Airport FAA LIAISON

LORI PAGNANELLI

ACI–NORTH AMERICA LIAISON A.J. MULDOON

TRB LIAISON

CHRISTINE GERENCHER

ACRP SYNTHESIS STAFF

STEPHEN R. GODWIN, Director for Studies and Special Programs JON M. WILLIAMS,Program Director, IDEA and Synthesis Studies GAIL STABA, Senior Program Officer

DON TIPPMAN, Editor

CHERYL KEITH, Senior Program Assistant TOPIC PANEL

STEWART DALZELL, Massachusetts Port Authority CHRISTINE GERENCHER, Transportation Research Board DAVID HENNESSY, Chesapeake Midstream Partners, L.P.,

Ft. Worth, TX

JULIE KENFIELD, Jacobs, San Antonio, TX THOMAS KLIN, CH2M Hill, Essex, CT

MICHAEL SCHNEIDERMAN, Michael Schneiderman Law Firm, Chicago

ROBIN R. SOBOTTA, Embry–Riddle Aeronautical University, Prescott, AZ

IAN WHITLOCK, Port of Portland (Oregon)

EDWARD MELISKY, Federal Aviation Administration (Liaison) PATRICK SULLIVAN, Federal Aviation Administration (Liaison) JESSICA STEINHILBER,Airports Council International–North

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formation already exists, either in documented form or as undocumented experience and practice. This information may be fragmented, scattered, and unevaluated. As a conse-quence, full knowledge of what has been learned about a problem may not be brought to bear on its solution. Costly research ﬁndings may go unused, valuable experience may be overlooked, and due consideration may not be given to recommended practices for solving or alleviating the problem.

There is information on nearly every subject of concern to the airport industry. Much of it derives from research or from the work of practitioners faced with problems in their day-to-day work. To provide a systematic means for assembling and evaluating such useful in-formation and to make it available to the entire airport community, the Airport Cooperative Research Program authorized the Transportation Research Board to undertake a continu-ing project. This project, ACRP Project 11-03, “Synthesis of Information Related to Air-port Practices,” searches out and synthesizes useful knowledge from all available sources and prepares concise, documented reports on speciﬁc topics. Reports from this endeavor constitute an ACRP report series, Synthesis of Airport Practice.

This synthesis series reports on current knowledge and practice, in a compact format, without the detailed directions usually found in handbooks or design manuals. Each report in the series provides a compendium of the best knowledge available on those measures found to be the most successful in resolving speciﬁc problems.

This synthesis study is intended to inform airport operators, including planners and en-vironmental documentation managers, about successful practices used to integrate airport development and federal environmental review processes.

Experience shows that when an airport sponsor fails to consider environmental issues during the airport planning process, delays in the FAA environmental decision-making processes often occur. Those delays occur because the FAA is unable to meet its National Environmental Policy Act (NEPA) obligations based on the data available. This may result in the FAA having to commission additional evaluation because:

• While the primary project was identiﬁed, the projects that were necessary to enable the primary project were not identiﬁed;

• Insufficient information is available to support the need for the project; and

• Impacts to resources protected by special purpose laws (i.e., wetlands, ﬂoodplains, parklands, historic resources, etc.) were not known and thus alternatives were not ex-plored that would avoid affecting the resources.

These issues are often referred to as a “disconnect” between the NEPA process and the steps that precede it. The airport community and the FAA have attempted to address the disconnect with improvements to the guidance and conferences to discuss the guidance and remaining issues. However, disconnect-related issues have continued to persist. In 2008, interested parties presented a synthesis project request to ACRP to examine this disconnect, which resulted in this project research. Seventeen case studies were collected and reported.

The surveys and case studies identiﬁed activities that airports performed to integrate planning and environmental review processes of projects at airports throughout the United States. Seven general themes can be drawn from the survey work:

PREFACE

By Gail Staba Senior Program Officer

Transportation Research Board

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• Coordinating State and Federal Environmental Review Processes • Funding an FAA Position.

Donald G. Andrews, Reynolds Smith and Hills, Inc., Houston; David J. Full, Reynolds Smith and Hills, Inc., San Francisco; and Mary L. Vigilante, Synergy Consultants, Inc., Seattle, collected and synthesized the information and wrote the report. The members of the topic panel are acknowledged on the preceding page. This synthesis is an immediately useful document that records the practices that were acceptable within the limitations of the knowledge available at the time of its preparation. As progress in research and practice continues, new knowledge will be added to that now at hand.

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1 SUMMARY

3 CHAPTER ONE DATA COLLECTION PROCESS Scope of Work, 3

Literature Review, 3 Coordination with FAA, 3 Survey of FAA, 3

Survey of Airport Sponsors, 3

Selection of Projects for Case Studies, 4

5 CHAPTER TWO CASE STUDIES Case Study 1, 5 Case Study 2, 6 Case Study 3, 7 Case Study 4, 8 Case Study 5, 9 Case Study 6, 11 Case Study 7, 12 Case Study 8, 13 Case Study 9, 14 Case Study 10, 14 Case Study 11, 16 Case Study 12, 17 Case Study 13, 18 Case Study 14, 19 Case Study 15, 20 Case Study 16, 21 Case Study 17, 21

23 CHAPTER THREE CONCLUSIONS Early Coordination and Consultation, 23

Knowing Your Airport (Know the On-Site Environmental Features), 23 Appropriate Range of Alternatives, 24

Good Lines of Communication, 24 Public Involvement Strategy, 24

Coordinating State and Federal Environmental Review Processes, 24 Funding an FAA Position, 25

26 GLOSSARY OF TERMS

27 APPENDIX A SURVEY

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As the lead federal agency for airport projects, the FAA complies with the National Environ-mental Policy Act (NEPA) for all federal actions. To aid in compliance with NEPA, the FAA has issued guidance in FAA Order 1050.1E (Federal Aviation Administration, Order 1050.1E,

Environmental Impacts: Policies and Procedures, Change 1,March 20, 2006), FAA Order 5050.4B [Federal Aviation Administration, Order 5050.4B, National Environmental Policy Act(NEPA) Implementing Instructions for Airport Actions,April 26, 2006] and the associated

Environmental Desk Reference for Airport Actions(October 2007), and the Desk Reference for Airport Actions.In completing its agency duties, the FAA is responsible for:

• Determining if an airport action is a categorical exclusion under NEPA,

• Reviewing environmental assessments prepared by airport sponsors or their consultants, • Ensuring that the environmental assessments meet FAA requirements, and

• Preparing environmental impact statements.

The FAA consults with the airport sponsor concerning proposed improvements to airport facilities. It is the policy of the FAA that airport sponsors, as owners and operators of the nation’s airports, are responsible for careful and thorough planning of their respective facil-ities. For purposes of this synthesis project, planning is a catch-all term to describe all efforts used to develop the concept and details of a proposed airport improvement. Planning may be a traditional Airport Master Plan, Airport Layout Plan Update, or it may be a series of tasks used to identify the need and scope of a project.

Experience shows that when an airport sponsor fails to consider environmental issues during the airport planning process, delays in the FAA environmental decision-making processes often occur. Those delays occur because the FAA is unable to meet its NEPA obligations based on the data available. This may result in the FAA having to commission additional evaluation because:

• Although the primary project was identiﬁed, the projects that were necessary to enable the primary project were not identiﬁed;

• Insufficient information is available to support the need for the project; and

• Impacts to resources protected by special purpose laws [i.e., wetlands, ﬂoodplains, departments of transportation 4(f) lands, etc.] were not known and thus alternatives were not explored that would avoid affecting the resources.

These issues are often referred to as a “disconnect” between the NEPA process and the steps that precede it. The airport community and the FAA have attempted to address the discon-nect with improvements to the guidance and conferences to discuss the guidance and remain-ing issues. However, disconnect-related issues have continued to persist. In 2008, a synthesis project request was presented to the ACRP to examine this disconnect, which resulted in this project study.

This synthesis project is an examination of why this disconnect occurs. This report focuses on identifying practices, both good and bad, that airport sponsors and FAA planners

SUMMARY

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and environmental specialists have used to integrate the sponsor’s airport planning efforts and the FAA’s environmental review processes.

For purposes of this synthesis report, “airport planning” includes any combination(s) of the following efforts that precede the start of the environmental review process:

• Airport Master Plan, Master Plan Update, or Airport Layout Plan Update; • Airport facility inventories;

• Modeling to determine operational efficiency of airport facilities; • Aviation forecasting;

• Facility needs evaluations, including demand/capacity evaluations; • Project formulation and justiﬁcation; and

• Analysis of alternatives that would achieve the airport sponsor’s proposed goals. For purposes of this synthesis report, the “environmental review process” includes all efforts to comply with NEPA and other federal environmental laws, regulations, executive orders, and department of transportation orders that may apply to a proposed project. (For a compilation of these requirements, see FAA Order 5050.4B and the 2007 Environmental Desk Reference for Airport Actions:http://www.faa.gov/airports_airtraffic/airports/environmental/environmental_ desk_ref/media_ref.pdf).

The surveys and case studies identiﬁed activities that airports performed to integrate plan-ning and environmental review processes of projects at airports throughout the United States. Seven general themes can be drawn from the survey work:

1. Early Coordination and Consultation

2. Knowing Your Airport (know the on-site environmental features) 3. Appropriate Range of Alternatives

4. Good Lines of Communication 5. Public Involvement Strategy

6. Coordinating State and Federal Environmental Review Processes 7. Funding an FAA Position.

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This section of the synthesis report provides an overview of the data collection process that was completed for the synthesis project.

SCOPE OF WORK

The consultant team prepared the draft work plan that was reviewed by the Topic Panel and the TRB representative. Comments on the draft work plan were received and a ﬁnal work plan was developed that responded to these comments.

LITERATURE REVIEW

No literature on integrating the airport planning and environ-mental review processes was identiﬁed. As a result, no liter-ature review was conducted as part of this synthesis project. Data were gathered through direct contact with the FAA and airport sponsors.

COORDINATION WITH FAA

The consultant team, along with the TRB representative, set up a series of conference calls with FAA Regional Environmen-tal Specialists. Each conference call involved from one to three FAA Regional Environmental Specialists and was intended to solicit information regarding which projects are the subject of additional review through a detailed survey. For purposes of this synthesis report, a full complement of airport projects in each region would have included three airport projects that were the subjects of Environmental Impact Statements (EISs), three airport projects that were the subjects of Envi-ronmental Assessments (EAs), and three airport projects that were subjects of Categorical Exclusions (CatExs). In some instances, FAA Regional Environmental Specialists were unable to identify a full complement of airports to receive the survey, as either the region had not had three EISs conducted in the last ﬁve years or the Regional Environmental Specialist may not have participated in EAs or CatExs.

SURVEY OF FAA

As part of the conference call, the FAA Regional Environ-mental Specialists were also interviewed to identify the issues associated with each of the integration efforts at the airports that received a survey. Although the original scope

of work would have had the FAA Regional Environmental Specialists complete a survey for each airport they identi-fied during their respective conference calls, it was decided (with input from FAA headquarters and TRB) that the FAA Regional Environmental Specialists would be interviewed to gather the information that the survey was intended to provide. Given the workload of the Environmental Special-ists, this approach was taken to maximize input.

The conference calls with the FAA Regional Environ-mental Specialists were candid and provided insight into the issues associated with the integration of the planning phase and the NEPA documentation phase of an airport improve-ment project.

SURVEY OF AIRPORT SPONSORS

A total of 46 surveys were distributed to airports throughout the United States. The survey instrument, which is presented in Appendix A, was developed to have airport sponsors pro-vide candid responses to describe their experience in integrat-ing their plannintegrat-ing efforts with the environmental review process. As with all survey instruments that have open-ended questions, interpretation of the questions resulted in some inconsistencies in terminology and, correspondingly, in some value judgments. A summary matrix was developed to pro-vide a comparison of responses by the airport sponsors. This summary matrix, which is presented in Appendix B, was developed as an overview of the responses. The categories presented in this matrix correlate to topics included in the sur-vey instrument. In preparing the summary matrix, an attempt was made to “standardize” responses to allow for compar-isons among the survey respondents. Some of the information contained in the summary matrix cannot be standardized because it is not possible to make direct comparisons among the information received from the airport sponsors. For example, the responses regarding the “Cost of NEPA” vary greatly—some airport sponsors provided the actual cost paid to the contractor to prepare the National Environmental Pol-icy Act (NEPA) document, whereas other airport sponsors factored in the time that airport sponsor staff took to manage the consultant and/or the cost of implementing mitigation mea-sures. Therefore, the summary matrix is presented not as a tool for determining conclusions associated with this synthesis project, but as a means for providing a quick comparison of the responses provided by the airport sponsors.

CHAPTER ONE

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Initially, seven airports responded to the survey. To increase the number of survey respondents, representatives at each of the remaining 39 airports were contacted to request their participation. The time period in which surveys could be received was extended to provide potential survey respon-dents with additional time to complete the survey. At the con-clusion of the outreach, a total of 17 project survey responses were received.

The 17 airports represented by the survey respondents range from large hub airports to general aviation airports. Thus, the survey has a fairly wide range of respondents to represent the experiences of sponsors in integrating the planning phase and the NEPA documentation. Presentation of the matrix (and the case studies) has been done in such a way to preserve anonymity among the survey respondents. Of the 17 responses, two were about airport projects that were subjects of CatExs, ﬁve were about airport projects that were subjects of EAs, and ten were about airport projects that were subjects of EISs.

Survey responses were received from at least one airport sponsor from each of the nine FAA Airports Office regions. The amount of detail provided by the survey respondents ranged from very detailed to minimal (as can be noted when comparing case study 5 to case study 16).

Some of the survey responses reinforce the concept that there is no common understanding of the NEPA process requirements and the steps available to streamline the process. Examples of apparent misunderstandings, which focus on the roles and responsibilities of various parties, were found in several of the survey responses. Examples of areas needing improved understanding include:

• Council on Environmental Quality regulations require that EISs be prepared by a federal agency. It is assumed that some airport sponsors responded as if they were preparing EISs because the airport sponsors fund the consultant effort, which is then managed by the federal agency. In some cases, owing to FAA staffing levels,

airport sponsors have funded a staff position at the FAA to oversee EIS work.

• Federal agencies are required to conduct certain agency coordination efforts, such as compliance with Section 106 of the National Historic Preservation Act, tribal coordination, and consultation in compliance with Sec-tion 7 of the Endangered Species Act. FAA offices often involve airport sponsors in those meetings owing to the unique understanding that airport sponsors have for their airports and proposed projects; however, the FAA has sole compliance responsibility.

• The roles of the various parties in advocating for projects and selecting alternatives to be implemented are speciﬁed in various sections of FAA Order 1050.1E and 5050.4B. • The FAA is not a proponent of projects. The FAA, in

compliance with its responsibility under NEPA, takes an unbiased, objective view of projects brought forward by an airport sponsor.

• Actions on projects can occur only after the FAA has issued a Finding of No Significant Impact or a Record of Decision in compliance with NEPA.

Industry groups, such as ACI–NA and AAAE, have spon-sored workshops that are designed to improve the understand-ing of the requirements of NEPA and to build better relation-ships between FAA regional and airport district offices.

SELECTION OF PROJECTS FOR CASE STUDIES

The consultant team included all 17 responding airports as case studies for this synthesis project. As a result, each airport sponsor that responded to the survey was re-contacted to gain additional information and insight into the issues that were identified in the survey by the airport sponsor. Some of the responses were modified to ensure that consistency in ter-minology was used in this synthesis report and that there was a clear understanding of the roles and responsibilities associated with each project. However, these modifications were not intended to alter the conclusions provided by the airport sponsor.

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This chapter presents the case studies for the 17 projects identified through the survey. Each case study includes a description of the proposed project, an identification of the key planning and environmental issues associated with the proposed project, the strategies that were used to integrate the planning and environmental review processes, and a discussion of the strategies used and other factors that would better integrate the planning and environmental review processes. The case studies presented in this chap-ter were prepared based on written survey responses and phone interviews to acquire additional information and insight into issues identified in the survey responses. As much information as possible was preserved from the tele-phone interviews that were conducted with each airport sponsor; however, some of the airport sponsor’s responses have been modified for consistency. In addition, some of the telephone interviews resulted in modifications to the information provided in the survey. Therefore, some incon-sistencies will be noted between the case studies and the matrix presented in Appendix B, the result of not modify-ing the initial survey responses provided by the airport sponsor.

CASE STUDY 1 Non-Hub Airport

Runway Safety Area Improvements Categorical Exclusion

Project Description

The FAA required the Proposed Project to enable the airport to comply with Runway Safety Area (RSA) requirements. The main driver behind the Proposed Project was the need to meet grant assurances requiring RSA compliance. The airport spon-sor’s planning and operations offices were responsible for the planning and initiation of the Proposed Project, whereas the design and environmental offices were responsible for the environmental review.

According to the sponsor, the FAA also acted as a key project proponent throughout the action. Additionally, future grants were awarded through the FAA and were based on the airport sponsor meeting the RSA requirements. To com-plete the project, the airport sponsor was also obligated to acquire the appropriate permits.

Key Planning Issues

The Proposed Project was part of the Airport Master Plan and was identiﬁed as a precondition by the FAA for other grants. A planning document was also produced that supported both the need and timing of the Proposed Project. Furthermore, the forecast and airﬁeld modeling data and analysis were current at the time of the environmental disclosure and analysis.

There were no key planning issues that concerned the par-ticipating agency and the affected public. The public showed limited interest in the Proposed Project, with few questions and comments throughout the process. Although no objections to the Proposed Project were received, the airport sponsor sent out newsletters, held public meetings, and communicated with local officials to keep the public aware of the actions taking place. Involving the public is a practice that provided the pub-lic with knowledge about the Proposed Project and allowed the public to participate in the planning process.

Key Environmental Issues

Environmental issues were considered as part of the planning process. The environmental process identiﬁed steps to mini-mize or avoid impacts by:

• Developing wetland mitigation,

• Developing mitigation of anadromous ﬁsh (ﬁsh that migrate from salt water to spawn in fresh water, such as salmon) stream impacts, and

• Avoiding known hazardous waste contamination areas. The environmental issues were addressed without any public opposition or litigation. According to the airport spon-sor, the public showed only slight interest in the Proposed Project, with no controversy identified or negative public comments.

The Proposed Project was coordinated with the following agencies: state environmental department, U.S. Army Corps of Engineers (USACE), state coastal zone department, U.S. Fish and Wildlife Service (FWS), and the National Marine Fisheries Service. The airport sponsor coordinated with these agencies through several meetings with the state environ-mental department. The sponsor worked with the state to resolve culvert- and stream-related issues. The airport spon-sor reduced the environmental impacts from the Proposed

CHAPTER TWO

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Project by adjusting the usable runway length and the air-craft approach angles. This enabled the preparation of a docu-mented CatEx, because no extraordinary circumstances would occur as a result of the implementation of the project

Strategies Used to Integrate Planning and Environmental Review Processes

NEPA compliance was accomplished for the Proposed Project under a documented CatEx. Additionally, the environmental review process was expedited by using the following methods: • Redesigning the Proposed Project to minimize impacts, • Coordinating early consultation with agencies and the

public, and

• Addressing agency concerns early in the planning process.

Discussion of Strategies Used and Other Factors That Would Better Integrate Planning and the Environmental Review Processes

The above-mentioned strategy of thorough communication among the involved parties led to the desired, uneventful, and successful integration between planning and the environmen-tal review process. Environmenenvironmen-tal considerations in the plan-ning phase allowed for issues to be discovered and resolved before the formal environmental review process was initiated, thus expediting the process.

Runway Safety Area Improvements Environmental Impact Statement

The FAA required the Proposed Project to enable the airport sponsor to meet RSA standards. The airport sponsor was made aware of the RSA deﬁciencies through the Airport Mas-ter Plan and Airport Layout Plan (ALP) updates, and certiﬁ-cation inspections done at the airport. The airport sponsor requested approval of non-standard RSA conditions. The FAA recognized the Proposed Project as an opportunity to address a matter of national priority. For the Proposed Project to be implemented, permits under Section 10 of the Rivers and Harbors Act and Sections 401/404 of Clean Water Act were required.

The airport sponsor’s planning group and a citizen-based project evaluation review committee were responsible for the planning of the Proposed Project. Although the use of such a committee can assist in reducing opposition to a Proposed Project, the airport sponsor did not indicate whether the use

of such a committee had that affect. In addition, the airport sponsor was responsible for coordinating with the FAA to initiate the environmental review process. Furthermore, the airport sponsor’s environmental staff was responsible for providing data for use in the environmental review of the Pro-posed Project.

The forecast prepared for the Proposed Project was consistent with that of the Terminal Area Forecast (TAF), as well as the forecast in the Airport Master Plan Update. The few differences among the three forecasts were considered minor and insignif-icant; therefore, no issues occurred with respect to the forecasts. The Proposed Project was not necessarily part of the Airport Master Plan Update; however, many of the same issues and solutions were recommended in both the Airport Master Plan Update and in the NEPA documentation.

Public opposition was expected to occur as a result of envi-ronmental issues (i.e., wetlands impacts, effects on the place-ment of ﬁll material, and wildlife impacts) that would result from the Proposed Project. The EIS contractor developed several programs and opportunities to communicate with the public. These outreach mechanisms included workshops, focus groups, study committees, newsletters, a website, pre-sentations of process elements, press releases, and newspaper articles.

Numerous outside agencies were involved with the Pro-posed Project. The participating agencies included the EPA, FWS, National Marine Fisheries Service, state department of ﬁsh and game, and two state environmental departments.

The key environmental issues are related to the fact that the airport is tightly constrained by natural features. As a result of these factors, the practical solution to the non-standard RSA included the placement of a large amount of fill mate-rial that may potentially affect an estuary and its fisheries and Section 4(f) resources. The estuary is used by the surround-ing community for subsistence and recreation purposes; therefore, public opposition to the placement of fill material was expected.

The environmental review process resulted in the need to do original research on a variety of natural resources, includ-ing population inventories for marine, estuarine, and palustrine species of ﬁsh, avians, and mammals. In addition, detailed physical inventories of terrain and bathymetry were obtained for the Proposed Project.

A key agency involved with the EIS was the FWS, which had a written agreement with the FAA for the reimbursement of expenses incurred through a survey conducted for the EIS.

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Despite the knowledge that the project was bound on one side by a department of transportation (DOT) 4(f) resource and on the other by a river, both of which are governed by Special Purpose laws, the Master Plan did not examine alter-natives designed to avoid impacts to these resources or to minimize effects. Further, during the EIS process, it was shown that the critical aircraft upon which the Proposed Proj-ect was based was not projProj-ected to be used at the airport. Thus, although the need for RSA correction was clear, the basis for selecting the airport sponsor’s proposed action was not ade-quately documented. As a result, substantial replanning was conducted during the EIS process to reconsider all possible alternatives and to coordinate the alternatives with agencies and the public.

Because the Master Plan provided little foundation for the Proposed Project, substantial delays were incurred in the environmental review process to reevaluate alternatives. Additionally, the lengthy and detailed studies included in the environmental review process delayed the initial review of the EIS.

The Proposed Project could have been improved if prior research and data had been used rather than performing mul-tiple analyses that repeated earlier research. Funding avail-ability for the EIS was an issue throughout the environmen-tal review process and acted as a primary concern for the airport sponsor and the FAA. Some of the budget strain could possibly have been eliminated if, again, repetitive analyses did not occur.

CASE STUDY 3

Medium Hub Airport Business Park

Environmental Assessment

The airport sponsor recommended the Proposed Project to encourage economic development on unused airport prop-erty. Economic development is a priority for the airport sponsor; thus, the business park (i.e., the Proposed Project) was highly sought. For the Proposed Project to be approved, obtaining permits in compliance with Section 404 of the Clean Water Act was required; therefore, coordination with USACE was necessary. Coordination with USACE was initiated before the start of the environmental review process.

TAF and current at the time of the preparation of the NEPA document. Consistency with the TAF was important for the Proposed Project because the business park included users that rely on air cargo operations. In addition, the planning docu-ments of the airport sponsor supported the need and timing of the Proposed Project.

The airport sponsor considered environmental resources as part of the planning effort and used the information to design the conceptual layout of the business park. The intent behind the conceptual layout was to minimize impacts to natural and environmental resources.

Environmental features were considered in the planning document and included wetlands, streams, floodplains, and surface traffic. The same issues were the focus of the NEPA documentation.

A signiﬁcant amount of public opposition to the Proposed Project was not anticipated (nor actually experienced); how-ever, precautionary measures and coordination with the involved agencies were taken. These included early coordina-tion, scoping, public hearings, and workshops. The following agencies were involved with the Proposed Project: state his-toric preservation officer, EPA, state environment depart-ment, USACE, National Resources Conservation Service, state DOT, FHWA, U.S. Department of Agriculture, various city and county departments, a local land trust agency, U.S. Department of the Interior, state clearinghouse, Federal Emer-gency Management AEmer-gency, state conservation department, a federally recognized tribe, National Park Service, and the regional planning council [metropolitan planning organiza-tion (MPO)]. Of the above-menorganiza-tioned agencies, no opposiorganiza-tion was anticipated or apparent toward the Proposed Project.

The airport sponsor proposed changes to the conceptual layout of the Proposed Project after the start of the environ-mental review process to accommodate the potential tenants of the business park. The changes to the Proposed Project delayed the environmental review schedule by three to four weeks as these changes in the conceptual layout were made. However, the revised conceptual layout did not result in any changes to the environmental impacts of the Proposed Proj-ect. Therefore, although the schedule was affected by this change in conceptual layout, no adjustment to the cost of the environmental review was warranted.

Several signiﬁcant strategies contributed to the successful project. Team communication, coordination with the FAA

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and concurrent internal team reviews all took place between the airport and involved agencies. As mentioned earlier, required permits were obtained from USACE as part of the environmental review process, which helped keep the Pro-posed Project moving forward. Thus, a practice to work with other federal agencies to incorporate their needs into the NEPA document so that the other federal agency can adopt the FAA-led NEPA document was used to integrate airport development and the environmental review.

Another practice used for this Proposed Project was to inte-grate environmental considerations into the planning process. The airport sponsor used information on environmental re-sources to design the business park to minimize impacts to wetlands, streams, and ﬂoodplains. This approach helped streamline of the NEPA document and avoid environmental issues.

The NEPA documentation was successfully completed with few public or agency comments. The communication and coordination, both before and during the environmental review process, contributed to the completion of the Pro-posed Project. Additionally, both the interested public and the various agencies had little or no opposition to the Pro-posed Project.

The change to the conceptual layout of the business park to accommodate the desires of the proposed users resulted in a delay in the review schedule. However, this delay was deemed to be acceptable because it did not result in any change in impacts to environmental resources and it was implemented to accommodate potential tenants of the busi-ness park.

Runway Safety Area Improvements Environmental Assessment

The Proposed Project was needed to bring the RSA into com-pliance with FAA standards and was required by the FAA grant assurances. The nonstandard RSAs were brought to the attention of the airport sponsor through recommendations from the Airport Master Plan update and FAA’s compliance inspection. The state aviation department (which is a separate department and is not the airport sponsor) was the key proj-ect proponent, with the airport sponsor’s planning and engi-neering offices being responsible for the project initiation and environmental review.

At the time of the environmental disclosure and analysis, the forecast and airﬁeld modeling data and analysis were current, and the airport sponsor’s forecast was consistent with the TAF. Thus, there were no planning issues in relation to the forecasts. The two agencies involved with the Proposed Project were the levee district and USACE. As a result, the airport sponsor arranged for meetings that included the FAA, the levee district, and USACE. The coordination and communi-cation associated with the levee district and USACE took place before the start of the environmental review process and throughout the preparation of the EA. The airport spon-sor also took precautionary measures to satisfy the interested public. This included public hearings, workshops, a website with draft materials, press releases, newspaper articles, meet-ings with USACE and levee districts, and meetmeet-ings with corporate aircraft users groups. These steps were all initiated, and meetings held, before the start of the EA and continued throughout the preparation of the EA. This is a practice that was used to involve agencies throughout the entire planning and NEPA documentation process. Of the involved and inter-ested parties, a minor amount of opposition occurred but was addressed before becoming an issue.

The key environmental issues considered before the start of the environmental review process included floodplain and floodways, noise, water quality, waters of the United States, and environmental justice. The primary issue encountered during preparation of the EA was associated with floodplains and there was intense opposition from the levee districts.

A change to the Proposed Project occurred, as the project was selected before FAA acceptance of the Engineered Ma-terial Arresting System (EMAS) as an alternative for address-ing RSA compliance. The Proposed Project was revised to reflect the various refinements to the FAA RSA guidance associated with the EMAS. The revised Proposed Project called for the use of the EMAS to avoid floodway impacts as anticipated by the sponsors’ consultant. The changes made to the Proposed Project affected the schedule of the environ-mental review, but in a positive way, because it resulted in a Proposed Project that could be implemented without signifi-cant environmental effects. This is a practice that was used to review the entire range of reasonable alternatives to determine which alternative would result in the least environmental impact while meeting the purpose and need of the proposed action.

The FAA, with the airport sponsor’s agreement, initiated a change to the environmental review process. The change was the addition of two hydraulic analyses to address con-cerns expressed by the levee districts; as with the availability of the EMAS, an alternative was found that would avoid or

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not an accepted technological alternative during the earlier timeframe. Thus, the unique circumstances of the timing of the project were affected by outside inﬂuences of technolog-ical development.

Strategies used to integrate planning and the environmental review processes incorporated communication and coordina-tion among involved agencies before the commencement of the Proposed Project. The intensive agency coordination done in the planning and environmental review processes expedited the environmental review and approval process.

The changes and delays that occurred in the Proposed Project as a result of the need for acceptance of the EMAS, first by the FAA and then by the airport sponsor, were unavoidable. The information with regard to the EMAS was not available at the commencement of the environmental review process; however, the later inclusion of the EMAS shows the beneﬁt of that process of identifying alternatives to minimize impacts. Therefore, this Proposed Project resulted in enhancing aviation safety while minimizing environmen-tal effects.

Coordination and communication among the FAA, the airport sponsor, involved agencies, and the public were key strategies that were used throughout the planning and NEPA documen-tation processes. This moved the Proposed Project along and allowed for issues expressed by the public and the levee dis-trict to be addressed and resolved without litigation. This inter-action also enabled the FAA to meet its mission to enhance aviation safety while minimizing environmental effects.

The change to the environmental review process was the result of the evolution of a technology that became available at the time of the Proposed Project that could eliminate impacts to the levees. The use of the EMAS had not been approved by the FAA at the time of the start of the planning process for the Proposed Project. Had the EMAS been an option at the beginning of the planning process, the two-year delay might have been avoided. Although this is a timing issue, the lesson to be learned from this project is research what options (including evolving technologies) are available and how alter-natives can be designed to avoid environmental impacts. This requires constant vigilance in working with the FAA to identify any potential revisions to design standards that the FAA may be considering.

New Runway and New Terminal Building Environmental Impact Statement

The Proposed Project was identified through the Airport Master Plan process, and the timing was in response to the forecast growth. The Proposed Project included new runways, a terminal facility, and related facilities. The additions were desired to allow the airport to safely and efficiently accom-modate future activity without incurring unacceptable aircraft operational delay.

The airport sponsor’s engineering and planning offices were instrumental in initiating the Proposed Project. The planning group was responsible for planning and project ini-tiation, and for providing data for the environmental review. The FAA independently reviewed the data for inclusion in the EIS. Processes related to the Proposed Project underway at the same time consisted of the project design and wetland permitting.

A planning document was produced for the Proposed Project that supported both the need and timing for the project. The forecast and airﬁeld modeling data and analysis were current at the time of environmental disclosure and analysis. The forecast was consistent with that of the TAF because it was within 10% of the TAF and, therefore, approved by the FAA for use in the NEPA documentation [see FAA Order 5050.4B, paragraphs 706.b(3)(a)–(c) for information regarding the use of forecasts that are different from the TAF]. Environmental features were considered throughout the planning phase.

The FAA was responsible for a signiﬁcant number of the federal actions, decisions, and determinations that took place before the commencement of the Proposed Project. Other agencies involved with the EIS were USACE, EPA, FWS, National Oceanic and Atmospheric Administration (NOAA), U.S. Department of Agriculture, FHWA, a variety of state departments, several county departments, area transit author-ity, and state regional park authority. Advance meetings regarding wetland mitigation and wetland permitting appli-cations were held between the airport sponsor and USACE, state environmental department, and county departments.

The FAA required a change to the original planned run-way separation for the Proposed Project. It was initially 4,000 ft; however, the change increased the separation to 4,300 ft. The change was the result of the FAA’s requirement to have at least 4,300 ft of separation between the centerlines of parallel runways. This separation is required to enable

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independent operations under instrument meteorological con-ditions. The extended separation was not considered in the ﬁrst stages of planning because the FAA’s policies on inde-pendent operations were emerging at the outset of the envi-ronmental review process.

The runway separation revision affected the schedule of the environmental review by delaying the preparation of the draft EIS by approximately three months. This change also resulted in the need to acquire additional land for the Proposed Proj-ect, which required a modiﬁcation to the project being studied in the EIS. The airport sponsor and the FAA jointly originated the change to the Proposed Project and agreed that the change was necessary for the completion of the project.

Several key environmental features were considered before the start of the EIS, including noise, wetlands, and historic and archeological resources. Environmental issues speciﬁcally encountered during the preparation of the NEPA document included stream impact mitigation, stormwater management, and the relocation of the National Oceanic and Atmospheric Administration’s National Weather Station (NOAA–NWS) facilities. The stream mitigation issues and the relocation of the NOAA–NWS facilities were not anticipated and had an effect on the schedule of the NEPA documentation effort.

During the preparation of the EIS, the state environmen-tal department and USACE introduced a new policy that required stream impacts to be mitigated separately from wet-land impacts. This policy was not ﬁnalized until after the Record of Decision; therefore, these mitigation strategies were not initially included in the stream mitigation step in the planning phase. The relocation of the NOAA–NWS facilities was another unexpected change that occurred during the preparation of the EIS. At the outset of the EIS, the Proposed Project would not have required substantial land acquisition. The changes in the FAA policy on runway separation for independent operations of parallel runways led to a redeﬁni-tion of the Proposed Project and the need to acquire land from both NOAA and private parties. Although the private parties were willing to sell land for the Proposed Project, coordination of the transfer of NOAA land was complex and time consuming.

Public opposition toward the Proposed Project was present and based on concerns with noise issues. Several mechanisms were used in public outreach, such as hearings, workshops, newsletters, a website with draft materials, and press releases.

The airport sponsor took a signiﬁcant number of steps before beginning the environmental review process to expedite the

process and to allow for a smooth transition between phases. The actions taken included the following:

• Completing a Part 150 noise study for ultimate devel-opment of the airport.

• Working with the surrounding counties to urge them to incorporate land use plans and zoning regulations that restrict noise-sensitive land use near the airport. • Adding an environmental engineer to the planning

depart-ment to provide a full-time employee to act as liaison to the FAA during the preparation of the EIS.

• Completing aviation activity forecasts and obtaining approval from the FAA for the non-TAF forecasts to be used in NEPA documentation.

• Brieﬁng the FAA Airport District Office and the Region Office on the Capital Construction Program as soon as it was approved by the sponsor’s board of directors. • Working with the FAA Airport District Office, region,

and headquarters to develop a comprehensive approach to environmental review processing for the entire Capital Construction Program.

• Performing airport-wide wetland delineation.

• Obtaining wetland mitigation credits sufficient to offset the anticipated project impacts to wetlands.

• Performing two years of airport-wide surveys of rare, threatened, and endangered species.

• Acquiring sufficient land for the Proposed Project. • Performing inventories of on-airport archaeological and

historic resources.

• Working closely with the FAA to establish a program-matic memorandum of agreement among the state historic preservation office, the Advisory Council on Historic Preservation, and the airport sponsor regard-ing Section 106 processregard-ing for airport projects. • Working with the state air agency and the MPO to ensure

that the State Implementation Plan for ozone included the project-related construction emissions, which was critical to the successful completion of the General Conformity Analysis and FAA’s General Conformity Determination.

The Proposed Project could have better transitioned between the planning and environmental review processes had the airport sponsor conducted the archaeological surveys and wetland delineations for off-airport property before the start of the environmental review process. The need to acquire the off-airport land did not emerge until after the environ-mental review process had begun; thus, the airport sponsor had no way of knowing the information would be needed.

For archeological surveys and environmental due dili-gence surveys for hazardous materials to be conducted, the airport sponsor, with approval from the FAA, used an on-call task order contract. These surveys expedited the environmen-tal review. The environmenenvironmen-tal review process was slowed because there was no scoping response from NOAA–NWS. With the redeﬁnition of the Proposed Project based on a

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Finally, the two counties in which the airport is located sub-mitted extensive comments both on the draft EIS and on the wetland permit application. Numerous meetings with the coun-ties were needed to resolve the comments, which also affected the time the FAA needed to complete the draft and ﬁnal EISs.

A signiﬁcant amount of work and planning took place before the start of the NEPA documentation. This resulted in a positive effect on the successful completion of the NEPA documenta-tion and the schedule for the environmental review process.

CASE STUDY 6 Large Hub Airport

New Runway, Terminal Development, and Support Facilities

Environmental Impact Statement

The Proposed Project was developed to meet the future capac-ity needs of the airport and was driven mainly by the airport sponsor’s executive office. The airport sponsor’s planning and construction offices were responsible for the planning, project initiation, and for providing data for use in the EIS. The Proposed Project was part of the Airport Master Plan and identiﬁed in an adequacy study prepared for the airport spon-sor and in a separate airport planning process.

The state’s environmental policy process was underway at the same time as the environmental review process. This process requires separate state approval of the Proposed Project.

The forecast and airﬁeld modeling data and analysis were current at the time of the Proposed Project and within accept-able variation of the TAF. A planning document was pro-duced with adequate justiﬁcation in planning for the design aircraft and planning documents that support the Proposed Project’s need and timing.

The Proposed Project went forward without any design changes from the airport sponsor or the FAA. The approach to the environmental review process was approved by the

All environmental issues identiﬁed by the state and fed-eral agencies were considered during the environmental review process. Two of these issues were key to the comple-tion of the NEPA documentacomple-tion: community noise issues and wildlife refuge impacts. As a result of the analysis of the impacts to the wildlife refuge, additional surveys and coordi-nation were necessary to fully address the issue. This resulted in additional time and cost associated with the completion of the analysis of wildlife refuge impacts.

All federal, state, and local agencies participated in the environmental review process, and had no concerns or objec-tions. The steps taken to coordinate with these interested agencies included technical advisory committees, agency-speciﬁc involvement in analyses, Memorandum of Under-standing development and execution, and extensive analysis coordinated with the FWS and state historic preservation officer. The sponsor also coordinated with the state environ-mental department officials.

The Proposed Project did receive a signiﬁcant amount of public opposition, speciﬁcally from individual citizens, citi-zen groups, and elected officials. The focus of the opposition was on the environmental review process (both federal and state) and aircraft noise issues. Litigation was anticipated and did occur.

The following mechanisms were used in the planning and environmental review process for public outreach:

• Hearings, • Workshops, • Study committees, • Newsletters, • Press releases,

• Newspaper articles, and • Peer review groups.

The Proposed Project transitioned well from the planning process into the environmental review process as a result of the environmental approvals being given for each step of the process. This was an integral part of the planning and decision-making phase. In addition, state approval of the Proposed Proj-ect was accomplished on a timeframe that was concurrent with the environmental review process. The airport sponsor coordi-nated with the FAA to ensure that the state environmental review process and the federal environmental review process were coordinated as much as possible and that duplication of effort in preparation of environmental review was minimized. This required the lead agency for the state environmental review process and the FAA to work together in identifying